Romania Issues Order to Amend Tax Payment Return for Global Minimum Tax
On February 7, 2025, Order no. 193 of 2025 was published in the Official Gazette. This provides amendments to the income tax return (form 100) to report amounts due under the IIR/UTPR or DMTT.
Denmark Issues a Draft Law for June 2024 and January 2025 OECD Administrative Guidance
On February 3, 2025, the Danish Ministry of Finance issued draft legislation (Bill 2024-4606) for consultation. This is to amend the Danish Minimum Tax Act for the June 2024 and January 2025 OECD Administrative Guidance.
Pillar Two: Domestic Registration Requirements
Many jurisdictions will require GloBE registration for administrative purposes, however, the law issued to date has been inconsistent. We outline the GloBE registration obligations from the domestic legislation (enacted and draft) issued to date, with citations and links to relevant laws.
A Detailed Review of France’s Global Minimum Tax Law
On 10 October 2024, the French Government presented the draft Finance Bill for 2025 to Parliament. This includes amendments to its General Tax Code to reflect the OECD Administrative Guidance, including the December 2023 OECD amendments to the Safe Harbours.
Liechtenstein Issues Pillar 2 Registration Rules
On January 9, 2025, Liechtenstein released its GloBE Registration form (submitted via email within 6 months of the end of the fiscal year).
Countries With Pillar 2 Provisions for Securitisation Entities
The Fourth Set of OECD Administrative Guidance (issued on June 17, 2024) includes guidance on the treatment of Securitization Entities.
A Review of Barbados’s Conditional Domestic Minimum Tax
On May 24, 2024, the Corporation Top-up Tax Act, 2024 was published in the Official Gazette. This implements a domestic minimum top-up tax intended to be a QDMTT for Pillar 2 purposes.
A Review of The Bahamas Pillar 2 Domestic Minimum Tax
On November 29, 2024, the Domestic Minimum Top-Up Tax Act, 2024 was published in the Official Gazette of The Bahamas. This implements a domestic minimum top-up tax intended to be a QDMTT for Pillar 2 purposes.
Finland’s Amendment Law and the Impact on its Global Minimum Tax Provisions
On December 19, 2024, Law 917/2024 was published in the Finnish Official Gazette to amend the Minimum Tax Act to reflect numerous aspects of the OECD Administrative Guidance. This applies to financial years beginning on or after January 1, 2024.
A Detailed Review of the Cyprus Global Minimum Tax Law
On December 18, 2024, Cyprus published the law to implement the EU Minimum Tax Directive its its Official Gazette. This implements the IIR from December 31, 2023 and a UTPR and domestic minimum tax from December 31, 2024.
